Multnomah County Circuit Court orders return of $340 cleaning deposit deduction

The Multnomah County Circuit Court entered judgment for Jordan Bell and ordered Cedar Key Rentals LLC to pay $340, the full amount withheld from Bell’s $900 security deposit for “professional cleaning.” Bell had sought return of the disputed deduction after Cedar Key returned the remaining $560.

The court found that Cedar Key proved it sent a written deposit accounting and returned the undisputed portion of the deposit. But it held that the accounting did not provide a sufficiently specific basis for retaining the $340.

No other relief was awarded on the record.

• Judgment entered for Jordan Bell.
• Cedar Key Rentals LLC must pay Bell $340.
• Bell’s request for return of the cleaning deduction was granted in full.

The court identified two central questions: whether Cedar Key’s written accounting specifically stated the basis for the cleaning deduction, and whether the landlord proved that the $340 represented a real tenant-related cleaning expense.

It held that the reference to “professional cleaning” was some accounting, but insufficiently specific on the evidence presented. The letter did not identify what condition was found, what cleaning work was performed, or why the charge was $340.

The record contained no separate invoice, cleaner identification, task list, inspection note, or description of the apartment condition requiring cleaning. Cedar Key acknowledged that its proof was limited to the deposit letter.

Bell’s evidence did not establish the apartment’s exact condition after surrender, the court said. Still, Bell’s text message to management stating that he had cleaned the kitchen and bathroom before returning the keys supported his account that he cleaned before moving out.

The court concluded that Cedar Key bore the burden to establish both the accounting and the justification for keeping the deposit money. It found that the missing detail meant the landlord had not met that burden.

“Proof of a label is not the same as proof of a specific basis.”

Bell argued that Cedar Key’s letter established only that a $340 deduction had been made, not why it was necessary. He pointed to the absence of a cleaning bill, cleaner name, task list, inspection record, move-out condition report, or calculation supporting the amount.

Bell also relied on a text exchange sent two days before key return. In it, Bell told the property manager that he had cleaned the kitchen and bathroom and would leave the keys the next day. The manager replied by directing Bell to leave the keys in the lockbox.

Cedar Key submitted that its written deposit accounting tied the charge to Bell’s apartment and showed that the deduction was not random or unrelated to the tenancy. It maintained that Bell had not proved the charge was invented or disconnected from the unit.

However, Cedar Key accepted that it had no separate cleaner’s invoice, task list, inspection note, or detailed breakdown of the work. Its position was that the written accounting nevertheless supported retaining the deduction, or at least denying a full refund.

Bell rented from Cedar Key Rentals LLC after moving into the complex around September 2022. He paid a $900 security deposit and, after the tenancy ended, returned the keys.

Cedar Key later sent an itemized deposit accounting that listed a $340 deduction for “professional cleaning” and showed a $560 balance returned to Bell. The return of the undisputed portion and the sending of the accounting were not disputed.

Bell described the apartment as being in ordinary lived-in condition when he surrendered it. He did not have move-out photographs or video, and the record did not include a final walk-through with management, a written move-in damage list, or pre-move-in photographs.

The recorded outcome is limited to the $340 cleaning deduction. The court did not award any additional relief and made no finding on other potential deposit claims beyond the evidence before it.